Portfolio Oversight Reporting

Monitoring of Investment Policy

  • We have procedures in place to ensure and verify that the investment policies and strategies of each AIF are complied with and to ensure availability of up to date information on portfolio performance.
  • Monitor the performance of your Fund against its benchmark and investigate any significant underperformance.
  • Ensure confirmations from the Head of Investments that the investment objectives, policies and strategies of the Funds continue to be complied with.
  • The Directors will approve the investment strategy for each CCM Fund as set out in the prospectus documentation on establishment of the Fund.
  • Carry out monthly investment reports.
  • Ensure that the general investment policy, the investment strategies and the risk limits (including market, credit, liquidity, counterparty and operational risk) of the relevant CCM Fund are properly and effectively implemented and complied with.
  • Ensure the adequacy of the internal procedures of CCM for undertaking investment decisions for a CCM Fund so as to ensure that such decisions are consistent with the approved investment strategies.
  • CCM has arrangements in place to ensure that investment decisions are carried out in compliance with the investment objectives, investment strategy and risk limits of the relevant CCM Fund.

Risk Management

  • Risk Management is integrated in every stage of CCM’s due diligence and investment process.
  • Our board has put in place procedures designed to ensure that all applicable risks pertaining to the AIFM and to AIFs under management can be identified, monitored and managed at all times.
  • We monitor the implementation of the Risk Management policy and procedures.
  • CCM has robust risk management structures, processes, systems, limits and controls to manage its risks.
  • We provide the Board with a quarterly Risk Management Report.
  • The Designated Person will rely on reports received from the relevant CCM Funds service provider in order to carry out its duties.

Operational Risk

  • CCM defines operational risks associated with supporting the operating environment of the CCM Funds.
  • We ensure that all applicable operational risks (accounting, administration, investment manager and depositary) pertaining to CCM and the CCM Funds can be identified, monitored and managed at all times.
  • CCM has put in place a risk management policy and procedures which identify the risks the CCM Funds are or might be exposed to, which include operational risks.
  • The operating environment includes middle and back office function such as trade processing, accounting, administration and valuation.
  • The administrator maintains comprehensive controls for calculating, recording, and reporting the NAV pricing of the Sub- Funds.

Liquidity Management

  • CCM has put in place a liquidity management policy and procedures which enables it to identify and monitor the liquidity risk of each CCM Fund.
  • We ensure that the liquidity profile of investments comply with its underlying obligations.
  • The liquidity management policy includes details on periodic stress testing carried out by CCM.
  • We manage the liquidity risk of the relevant CCM Fund in exceptional and extraordinary circumstances.

AIFMD Reporting

  • CCM has in place procedures designed to ensure that it complies with its obligations under the AIFMD Level 2.
  • The designated individual is responsible for ensuring that the company submits all necessary reporting to the Central Bank as required by the regulations.
  • We provide reports confirming that CCM is in compliance with the AIFMD reporting and transparency requirements including data submitted and deadlines including any failures by the Administrator to meet its obligations to file reports with the Central Bank.

Monitoring Compliance

  • CCM has appointed the Head of Risk and Compliance as the permanent compliance officer with responsibility for the compliance function.
  • Ensuring compliance with all legal and regulatory requirements of CCM and each AIF it manages.
  • Our board has in place procedures designed to ensure compliance with all applicable legal and regulatory requirements of the AIFM itself and all AIFs under management.
  • We produce monthly Operations reports, Risk management reports, CCM compliance reports and ‘Designated client reports’.
  • Records are retained as required by applicable regulations and are available to the Head of Risk & Compliance.
  • Regular training of staff on both the businesses and each staff members’ personal objectives.